CIP FAQs – How should a bank verify the identity of a sole proprietorship that opens a new account, when there are no documents or non-documentary methods that will establish the identity of the sole proprietorship?

Compliance > BSA > FinCEN FAQs - CIP
Q:  How should a bank verify the identity of a sole proprietorship that opens a new account, (such as an account titled in the name of an individual “doing business as” a sole proprietorship) when there are no documents or non-documentary methods that will establish the identity of the sole proprietorship?
 
A:  In some states, sole proprietorships are required to file “fictitious” or “assumed name certificates.”  Banks may choose to use these certificates as a means to verify the identity of a sole proprietorship, if appropriate.  However, when there are no documents or non-documentary methods that will establish the identity of the sole proprietorship, the bank must undertake additional verification by obtaining information about the sole proprietor or any other individual with authority or control over the sole proprietorship account -- such as the name, address, date of birth, and taxpayer identification number of the sole proprietor, or any other individual with authority or control over the account -- in order to verify the sole proprietorship’s identity, as described in 31 C.F.R. § 103.121(b)(2)(ii)(C).  (January 2004)
 

ADDITIONAL INFORMATION
This FAQ was excerpted from the Interagency Interpretive Guidance on CIP Requirements that can be found at the following link:  https://www.fincen.gov/sites/default/files/guidance/faqsfinalciprule.pdf
 

Add Feedback